SOLUCIONES DE PAGOS Y RECAUDOS S.A.S. – “FINITY”
Public summary · November 2026
Our commitment to a financial system with integrity
At Finity we do not allow our services to be used for money laundering, terrorism financing or financing the proliferation of weapons of mass destruction (ML/TF/PF). To prevent it, we have a self-control and risk management system for these risks, documented in our AML/CFT Manual and our AML Policy, overseen by a Compliance Officer.
This document summarizes the main aspects of that system for our clients, partners and the general public.
Framework
Our system is based on Chapter X of the Basic Legal Circular of the Colombian Superintendence of Companies (SAGRILAFT), the recommendations of FATF and GAFILAT, and the lists that are binding in Colombia, as well as other national and international restrictive lists.
What we do
- We know our clients before onboarding them. We identify the company, its representatives, shareholders and ultimate beneficial owners, its economic activity and the source of its funds.
- We apply enhanced due diligence to higher-risk clients, politically exposed persons and transactions related to high-risk sectors or countries.
- We screen against restrictive lists at onboarding and periodically thereafter. We do not onboard or deal with persons included in binding lists.
- We monitor transactions based on red flags and request supporting documents when a transaction does not match the client’s profile.
- We report to the UIAF (Colombia’s Financial Intelligence Unit) suspicious transactions and the other reports required by law.
- We keep records of onboarding and transactions for the period required by law.
- We train our team in the prevention of these risks.
What we do not accept
- Clients who do not provide their onboarding or source-of-funds information.
- Shell companies, or companies whose ultimate beneficial owner cannot be identified.
- Activities and jurisdictions that are prohibited or high-risk under our policies.
- Transactions split up in order to evade controls.
What we expect from our clients
- That they provide truthful information and keep it up to date.
- That they respond to requests for information or supporting documents within the periods set out in the agreement.
- That they have their own prevention controls in place when required by law.
If a client does not meet these conditions, Finity may refrain from processing a transaction, suspend the service or terminate the relationship. When there are signs of ML/TF/PF, the suspension may be immediate.
Reporting channel
Anyone can confidentially report a suspicious situation by writing to cumplimiento@finity.com.co.
This English version is provided for convenience. In case of any discrepancy, the Spanish version shall prevail.
